Communities and Local Government CommitteeWritten evidence from the Royal Institution of Chartered Surveyors (RICS)

RICS—Royal Institution of Chartered Surveyors—is pleased to respond to the Select Committee’s inquiry into the National Planning Policy Framework.

RICS is the leading organisation of its kind in the world for professionals in property, construction, land and related environmental issues. As an independent and chartered organisation, RICS regulates and maintains the professional standards of over 91,000 qualified members (FRICS, MRICS and AssocRICS) and over 50,000 trainee and student members. It regulates and promotes the work of these property professionals throughout 146 countries and is governed by a Royal Charter approved by Parliament which requires it to act in the public interest.

General Comments

RICS welcomes the Government’s draft National Planning Policy Framework as a significant step forward in enabling the growth the UK requires. We are pleased to see this concise outline of strategic national planning policy which retains its focus on economic development but emphasises the need to achieve this in a sustainable way. Businesses and other potential employers need the clarity and certainty which RICS believes the Government’s draft NPPF provides. We also believe that the draft strikes the right balance in safeguarding the environment and promoting strong, vibrant and healthy communities.

The existing planning system, however well intentioned, has failed to meet the demand for adequate, affordable housing and to deliver the economic growth the UK so badly needs. The proposals outlined in the National Planning Policy Framework (NPPF) will reduce the burdensome cost of the current planning system and this increased flexibility will help deliver housing, drive economic growth and encourage innovation.

RICS believe planning reform is just one element of creating the conditions required to deliver much needed affordable housing and economic expansion. Funding new infrastructure and adequate, responsible mortgage lending are just two more pieces of the jigsaw. As a cross-sectoral professional body acting in the public interest, RICS is considering these and other issues alongside the NPPF.

RICS Offers Answers to your Questions as Follows

It would arguably be difficult for Government to reach a definition of “sustainable development” which is completely agreeable to all parties. It will be up to Local and Neighbourhood Plans to refine the approach according to local priorities. RICS believes this will bring about a planning system which is more workable for the local community and more responsive to public need and this is therefore to be welcomed. How economic, social and environmental need are interpreted and balanced in both policy and development management will differ between geographic location and at different stages of the economic cycle. Without a clearer understanding of what constitutes sustainable development, this may give rise to legal challenges which will inevitably lead to uncertainty and delay.

The proposed presumption in favour of sustainable development seeks to enable development in Local Authorities where an up to date Local Plan or Neighbourhood Plan is not in place—where it is “absent, silent, indeterminate or where relevant policies are out of date”. The idea that the default answer to development proposals should be “yes”, subject to ensuring their impacts are acceptable, already applies in other significant policy areas, such as renewable energy. With approximately 65% of Local Authorities currently without an up to date Local Plan, the presumption will empower Local Planning Authorities to bring forward much needed development. It is vital that full coverage of Local Plans is achieved as soon as possible and is kept up to date. In the absence of Local Plans, development may be unsustainable and at odds with local needs and wishes. However, in light of pressure on resources in local authorities, it may still take time for Local Plans to be put in place. The ultimate challenge for Local Authorities will be to ensure that all local plans are brought into conformity with the NPPF.

It is the RICS view that the proposed presumption is a significant step forward in creating the conditions for growth by seeking to ensure the planning system “delivers” development. Key policies to protect the natural environment remain in place such as Green Belt protection, Areas of Outstanding Natural Beauty and Sites of Special Scientific Interest (SSSIs). Areas protected by these policies will not be affected by the presumption. The Government’s recent Natural Environment White Paper will also be a key document in delivering protection of the natural environment by setting out how communities will be able to safeguard vitally important green spaces whilst ensuring necessary development occurs sustainably.

RICS welcomes the overall approach of examining whether a Local Authority has fulfilled its “duty to co-operate” as a measure of soundness for Local Plans. Further guidance on what standard of co-operation is required to past the test of soundness would be welcome, possibly from The Planning Inspectorate.

RICS welcomes the this concise outline of national planning policy at a strategic level rather than the thousands of pages of guidance that currently lose the thrust of what the Government is trying to achieve and often alienates communities. These thousands of pages of guidance required a large amount of evidence to satisfy it which was challenging for communities and created delay and uncertainty for developers. The NPPF’s reference to a “proportionate” evidence base and requirement that the Local Plan is based on adequate, relevant and up-to-date evidence about economic, social and environmental factors in the local area is to be welcomed.

The “measure of soundness” that Local Authorities prepare their plans positively to meet objectively assessed need and infrastructure requirements may be challenging in the current era of financial constraint. If the NPPF made it clear that Local Authorities have a duty to take into account the needs and requirements assessed by other bodies and interests, and, to the extent they agree with them, adopt them, Local Authorities would be able to meet the requirements for evidence more easily. RICS would welcome a clearer definition of this measure of soundness.

RICS is now consulting with members on the NPPF and will be responding to Government in detail in due course. Professional guidance and standards will be key in ensuring the delivery of a workable planning system that operates in the public interest. RICS is consulting with members on two pieces of guidance to accompany the NPPF, “Financial Viability in Planning”, to support paragraphs 39–43 and “Place Making and Value” to support paragraphs 114–123.

September 2011

Prepared 20th December 2011